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    <title>2023 (11) TMI 80 - ITAT DELHI</title>
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    <description>Deployment of trust funds in Prakash Hospital Pvt. Ltd. was treated as yielding an economic benefit through interest saved on borrowing, so notional interest was accepted as the basis for taxing the benefit and the addition was sustained. A breach of charitable trust investment or application conditions did not justify denial of section 11 exemption for the entire income; only the income attributable to the non-compliant investment or deposit was taxable, and the balance exemption remained available. The assessee&#039;s exemption was therefore substantially upheld while taxation was confined to the tainted income.</description>
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      <title>2023 (11) TMI 80 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=445189</link>
      <description>Deployment of trust funds in Prakash Hospital Pvt. Ltd. was treated as yielding an economic benefit through interest saved on borrowing, so notional interest was accepted as the basis for taxing the benefit and the addition was sustained. A breach of charitable trust investment or application conditions did not justify denial of section 11 exemption for the entire income; only the income attributable to the non-compliant investment or deposit was taxable, and the balance exemption remained available. The assessee&#039;s exemption was therefore substantially upheld while taxation was confined to the tainted income.</description>
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